Expert Analysis

Cross-border transactions and interpretation of related international tax treaties often involves controversies and issues concerning interpretation of treaty provisions and thereby leads to litigation with tax authorities. A recent judgment of the Tax Tribunal (Tribunal) in India in the case of Apollo Hospital Enterprises Limited (AHEL), has given rise to a debate regarding the interpretation of the expression “may be taxed” used in the India – Sri Lanka double taxation avoidance agreement (Treaty). Sanjay Sanghvi and Ashish Mehta, of Khaitan & Co, explore the implications.

Ireland has used tax policy wisely in its effort to fix its economy. What businesses need from this year’s Budget and in the next few years is certainty, believes Martin Phelan, president of the Irish Tax Institute.

The interaction of Poland’s transfer pricing rules and reimbursement law means the pharmaceutical industry is faced with complex compliance demands, explains Aneta Blazejewska-Gaczynska and Slawomir Buszko of Ernst & Young.

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Maria Gouveia of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the most widespread misconceptions surrounding the regime, clarifying its tax deferral mechanism, effective rates, eligibility criteria, and scope

Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks